The U.S. Apple Association (USApple) is the national trade association representing all segments of the apple industry. Members include 36 state apple associations representing apple growers throughout the country as well as packers, shippers, processors, importers, brokers and affiliated companies across the marketing chain.

We are writing this letter to express opposition to the granting of nonregulated status for two genetically engineered (GE) varieties of apples, referred to as events GD743 and GS784, developed by Okanagan Specialty Fruits, Inc.(OSF) of Summerland, British Columbia, Canada.

According to the OSF petition for deregulation, the two varieties of genetically engineered (G.E.) apples pending before your department are intended to be marketed as “non-browning” apples. In the opinion of USApple, this attribute is insufficient to warrant introduction into and possible disruption of the consumer marketplace. It should be noted, however, that USApple does not believe these apples represent a human health concern.

I would like to emphasize that the apple industry strongly supports apple genetics and genomics research geared towards solving problems associated with diseases and insects that attack apples, as well as research conducted as part of USDA’s national rootstock breeding program. USApple believes application of biotechnology may yield valuable attributes in the future.

The genetically modified apples in the petition offer questionable commercial benefit yet raise serious marketing questions for virtually all segments of our industry. In addition to the questionable commercial benefits, we believe that granting the request for deregulation could lead to significant and unnecessary costs to the industry in the form of labeling and marketing efforts that would be required to differentiate conventional apples from the GE apples.

Another key area of concern is the potential impact on export markets. Exports are extremely valuable for our industry. Approximately 29 percent of the U.S. fresh apple volume is sold overseas each year. In 2011, exports accounted for 36 percent of the value of $2.7 billion farm-gate production total for apples. More than $1 out of every $3 in apple revenue is derived from exports.

For the reasons stated above, USApple requests that the USDA Animal and Plant Inspection Service (APHIS) deny the petition for nonregulated status for genetically modified apples referenced in Petition 10-161-01p.

Sincerely yours,

Nancy E. FosterPresident and CEO

TK: Bottom line, the apple industry simply isn't ready for this GMO non-browning apple variety. From a marketing and PR perspective, the majority of grower-shippers and marketers feel they must oppose the Arctic, despite the fact that "application of biotechnology may yield valuable attributes in the future."

The marketing costs versus benefits equation is a nuanced approach to the question of Arctic apple approval by the USDA. Like the many emotional comments of consumers, the industry's more sober opinion may not still deliver enough science to speak to the outcome of the agency's deliberation.